Iowa Code

Iowa Code § 598.21 (2026)

Orders for disposition of property

✓ current as of July 2026
Find cases: SyfertCases citing this section IA-LEGlegis.iowa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

1. General principles. Upon every judgment of annulment, dissolution, or separate maintenance, the court shall divide the property of the parties and transfer the title of the property accordingly, including ordering the parties to execute a quitclaim deed or ordering a change of title for tax purposes and delivery of the deed or change of title to the county recorder of the county in which each parcel of real estate is located. 2. Duties of county recorder. The county recorder shall record each quitclaim deed or change of title and shall collect the fee specified in section 331.507, subsection 2, paragraph “a”, and the fees specified in section 331.604. 3. Duties of clerk of court. If the court orders a transfer of title to real property, the clerk of court shall issue a certificate under chapter 558 relative to each parcel of real estate affected

\n

Tue Dec 09 22:00:11 2025 Iowa Code 2026, Chapter 598 (41, 1) 13 DISSOLUTION OF MARRIAGE AND DOMESTIC RELATIONS, §598.21\n\nby the order and immediately deliver the certificate for recording to the county recorder of the county in which the real estate is located. Any fees assessed shall be included as part of the court costs. The county recorder shall deliver the certificates to the county auditor as provided in section 558.58, subsection 1. 4. Property for children. The court may protect and promote the best interests of children of the parties by setting aside a portion of the property of the parties in a separate fund or conservatorship for the support, maintenance, education, and general welfare of the minor children. 5. Division of property. The court shall divide all property, except inherited property or gifts received or expected by one party, equitably between the parties after considering all of the following: a. The length of the marriage. b. The property brought to the marriage by each party. c. The contribution of each party to the marriage, giving appropriate economic value to each party’s contribution in homemaking and child care services. d. The age and physical and emotional health of the parties. e. The contribution by one party to the education, training, or increased earning power of the other. f. The earning capacity of each party, including educational background, training, employment skills, work experience, length of absence from the job market, custodial responsibilities for children, and the time and expense necessary to acquire sufficient education or training to enable the party to become self-supporting at a standard of living reasonably comparable to that enjoyed during the marriage. g. The desirability of awarding the family home or the right to live in the family home for a reasonable period to the party having custody of the children, or if the parties have joint legal custody, to the party having physical care of the children. h. The amount and duration of an order granting support payments to either party pursuant to section 598.21A and whether the property division should be in lieu of such payments. i. Other economic circumstances of each party, including pension benefits, vested or unvested. Future interests may be considered, but expectancies or interests arising from inherited or gifted property created under a will or other instrument under which the trustee, trustor, trust protector, or owner has the power to remove the party in question as a beneficiary, shall not be considered. j. The tax consequences to each party. k. Any written agreement made by the parties concerning property distribution. l. The provisions of an antenuptial agreement. m. Other factors the court may determine to be relevant in an individual case. 6. Inherited and gifted property. Property inherited by either party or gifts received by either party prior to or during the course of the marriage is the property of that party and is not subject to a property division under this section except upon a finding that refusal to divide the property is inequitable to the other party or to the children of the marriage. 7. Not subject to modification. Property divisions made under this chapter are not subject to modification. 8. Necessary content of order. Orders made pursuant to this section need mention only those factors relevant to the particular case for which the orders are made but shall contain the names, birth dates, addresses, and counties of residence of the petitioner and respondent. [C51, §1485; R60, §2537; C73, §2229; C97, §3180; C24, 27, 31, 35, 39, §10481; C46, 50, 54, 58, 62, 66, §598.14; C71, 73, 75, 77, 79, §598.17, §598.21; C81, §598.21; 82 Acts, ch 1054, §1, ch 1250, §4 – 9] 83 Acts, ch 101, §118; 85 Acts, ch 159, §10; 85 Acts, ch 178, §6, 7; 86 Acts, ch 1079, §5; 88 Acts, ch 1141, §2; 89 Acts, ch 102, §6; 89 Acts, ch 166, §6; 90 Acts, ch 1224, §42 – 45; 92 Acts, ch 1195, §405, 406, 508, 509; 93 Acts, ch 78, §44 – 46; 93 Acts, ch 79, §48, 49; 94 Acts, ch 1171, §40 – 42; 95 Acts, ch 52, §8; 95 Acts, ch 115, §11, 12; 96 Acts, ch 1106, §17; 96 Acts, ch 1141, §7, 28, 29; 97 Acts, ch 41, §32; 97 Acts, ch 175, §188 – 193, 200; 99 Acts, ch 103, §44, 45; 2001 Acts, ch 143, §8; 2002 Acts, ch 1018, §16, 17, 21; 2003 Acts, ch 151, §28; 2004 Acts, ch 1157,

\n

Tue Dec 09 22:00:11 2025 Iowa Code 2026, Chapter 598 (41, 1) §598.21, DISSOLUTION OF MARRIAGE AND DOMESTIC RELATIONS 14\n\n§1; 2005 Acts, ch 69, §38; 2007 Acts, ch 163, §1 – 3; 2009 Acts, ch 27, §36; 2009 Acts, ch 159, §14; 2009 Acts, ch 179, §44 Referred to in §321A.17, 557.15, 598.20, 598.21A

\n
Notes of Decisions
Amended July 31, 2015 In RE the Marriage of Susan Michelle Thatcher & Ronald Dean Thatcher Upon the Petition of Susan Michelle Thatcher, Anna Carson as for the Est. of Susan Michelle Thatcher, 864 N.W.2d 533 (Iowa 2015). · cites it 112× “Iowa Code § 598.21 (emphasis added). We conclude the plain language of this provision requires a division of property contemporaneous with the decree of dissolution.”
In RE the Marriage of Rachel A. McDermott & Stephen J. McDermott Upon the Petition of Rachel A. McDermott, 827 N.W.2d 671 (Iowa 2013). · cites it 41× “Other economic circumstances of each party . . .”
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). · cites it 47× “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
In Re the Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006). · cites it 23× “(citing Iowa Code § 598.21 (1) (2003)). Importantly, “the property included in the divisible estate includes not only property acquired during the marriage by one or both of the parties, but property owned prior to the marriage by a party.”
In Re the Marriage of Rosenfeld, 668 N.W.2d 840 (Iowa 2003). · cites it 44× “” Iowa Code § 598.21 (5A). The court shall determine “the reasonable costs for only necessary postsecondary education expenses.”
In Re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005). · cites it 24× “Iowa Code § 598.21 (3)( a )-( g ), ( j ).”
In Re the Marriage of Thielges, 623 N.W.2d 232 (Iowa Ct. App. 2000). · cites it 34× “His arguments are based on the decree’s relocation restriction and section 598.21(8A), a provision of the Iowa Code applicable to long-distance relocations.”
In Re the Marriage of McKenzie, 709 N.W.2d 528 (Iowa 2006). · cites it 25× “Iowa Code § 598.21 (8) (2003). 1 The Code also contained an additional ground for modification of child support.”
In Re the Marriage of Pals, 714 N.W.2d 644 (Iowa 2006). · cites it 29× “Iowa Code § 598.21 (8) (2003). To constitute a “substantial change in circumstances,” the changed conditions “ ‘must be material and substantial, not trivial, more or less permanent or continuous, not temporary, and must be such as were not within the knowledge or contemplation…”
In Re the Marriage of Steven Michael Gust & Linda Leann Gust Upon the Petition of Steven Michael Gust, 858 N.W.2d 402 (Iowa 2015). · cites it 12× “1175, § 3 (codified at Iowa Code § 598.21 (3) (1981)). Under the current version of Iowa Code section 598.”
In Re the Marriage of Schriner, 695 N.W.2d 493 (Iowa 2005). · cites it 15× “2d 205, 207 (Iowa 1987) (citing Iowa Code § 598.21 (1) (1985)). See generally Joseph A.”
In Re Marriage of Fennelly & Breckenfelder, 737 N.W.2d 97 (Iowa 2007). · cites it 10× “Iowa Code § 598.21 (1). In the present case, the parties agreed to equally divide all property acquired during the marriage.”
— Iowa Code § 598.21(1) — 101 cases
Amended July 31, 2015 In RE the Marriage of Susan Michelle Thatcher & Ronald Dean Thatcher Upon the Petition of Susan Michelle Thatcher, Anna Carson as for the Est. of Susan Michelle Thatcher, 864 N.W.2d 533 (Iowa 2015). “Iowa Code § 598.21 (emphasis added). We conclude the plain language of this provision requires a division of property contemporaneous with the decree of dissolution.”
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
In Re the Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007).
In Re the Marriage of Anliker, 694 N.W.2d 535 (Iowa 2005).
In Re the Marriage of Johnson, 781 N.W.2d 553 (Iowa 2010).
— Iowa Code § 598.21(1)(a) — 1 case
— Iowa Code § 598.21(1)(b) — 1 case
In Re the Marriage of Wendell, 581 N.W.2d 197 (Iowa Ct. App. 1998).
— Iowa Code § 598.21(1)(g) — 2 cases
In Re the Marriage of Woodward, 426 N.W.2d 668 (Iowa Ct. App. 1988).
In Re the Marriage of Ales, 592 N.W.2d 698 (Iowa Ct. App. 1999).
— Iowa Code § 598.21(1)(i) — 1 case
In Re the Marriage of Van Brocklin, 468 N.W.2d 40 (Iowa Ct. App. 1991).
— Iowa Code § 598.21(1)(k) — 4 cases
In Re the Marriage of Hansen, 465 N.W.2d 906 (Iowa Ct. App. 1990).
In Re the Marriage of Butterfield, 500 N.W.2d 95 (Iowa Ct. App. 1993).
In re the Marriage of Hansen (Iowa Ct. App. 2018).
— Iowa Code § 598.21(1)(m) — 1 case
In Re the Marriage of Goodwin, 606 N.W.2d 315 (Iowa 2000).
— Iowa Code § 598.21(1)(to) — 1 case
In Re the Marriage of Cooper, 769 N.W.2d 582 (Iowa 2009).
— Iowa Code § 598.21(1)(⅛) — 1 case
In Re the Marriage of Cooper, 769 N.W.2d 582 (Iowa 2009).
— Iowa Code § 598.21(11) — 3 cases
In Re the Marriage of Johnson, 781 N.W.2d 553 (Iowa 2010).
Garrett v. Huster, 684 N.W.2d 250 (Iowa 2004).
— Iowa Code § 598.21(2) — 31 cases
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
In Re the Marriage of Muelhaupt, 439 N.W.2d 656 (Iowa 1989).
In Re the Marriage of Sparks, 323 N.W.2d 264 (Iowa Ct. App. 1982).
In Re the Marriage of Thomas, 319 N.W.2d 209 (Iowa 1982).
In Re the Marriage of Vrban, 359 N.W.2d 420 (Iowa 1984).
— Iowa Code § 598.21(3) — 77 cases
In Re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005). “Iowa Code § 598.21 (3)( a )-( g ), ( j ).”
In Re Marriage of Becker, 756 N.W.2d 822 (Iowa 2008).
In Re the Marriage of Anliker, 694 N.W.2d 535 (Iowa 2005).
In Re the Marriage of Spiegel, 553 N.W.2d 309 (Iowa 1996).
In Re Marriage of Estlund, 344 N.W.2d 276 (Iowa Ct. App. 1983).
— Iowa Code § 598.21(3)(1) — 2 cases
In Re the Marriage of Orgren, 375 N.W.2d 710 (Iowa Ct. App. 1985).
In Re the Marriage of Schober, 379 N.W.2d 46 (Iowa Ct. App. 1985).
— Iowa Code § 598.21(3)(1993) — 1 case
In Re the Marriage of Ask, 551 N.W.2d 643 (Iowa 1996).
— Iowa Code § 598.21(3)(1995) — 1 case
In Re the Marriage of Hettinga, 574 N.W.2d 920 (Iowa Ct. App. 1997).
— Iowa Code § 598.21(3)(b) — 2 cases
In Re Marriage of Earsa, 480 N.W.2d 84 (Iowa Ct. App. 1991).
In Re the Marriage of Brown, 462 N.W.2d 683 (Iowa Ct. App. 1990).
— Iowa Code § 598.21(3)(c) — 4 cases
In Re the Marriage of Johnson, 781 N.W.2d 553 (Iowa 2010).
In Re the Marriage Probasco, 676 N.W.2d 179 (Iowa 2004).
In Re the Marriage of Brown, 462 N.W.2d 683 (Iowa Ct. App. 1990).
— Iowa Code § 598.21(3)(d) — 1 case
In Re the Marriage of Brown, 462 N.W.2d 683 (Iowa Ct. App. 1990).
— Iowa Code § 598.21(3)(e) — 9 cases
In Re the Marriage of Wegner, 434 N.W.2d 397 (Iowa 1988).
In Re the Marriage of Griffin, 356 N.W.2d 606 (Iowa Ct. App. 1984).
In Re the Marriage Probasco, 676 N.W.2d 179 (Iowa 2004).
In Re Marriage of Estlund, 344 N.W.2d 276 (Iowa Ct. App. 1983).
In Re the Marriage of Johnson, 781 N.W.2d 553 (Iowa 2010).
— Iowa Code § 598.21(3)(f) — 2 cases
In Re the Marriage of Grauer, 478 N.W.2d 83 (Iowa Ct. App. 1991).
In Re the Marriage of Brown, 462 N.W.2d 683 (Iowa Ct. App. 1990).
— Iowa Code § 598.21(3)(i) — 1 case
In Re the Marriage of Pillard, 448 N.W.2d 714 (Iowa Ct. App. 1989).
— Iowa Code § 598.21(3)(j) — 3 cases
In Re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005). “Iowa Code § 598.21 (3)( a )-( g ), ( j ).”
In Re the Marriage of Cerven, 335 N.W.2d 143 (Iowa 1983).
In Re the Marriage of Brown, 462 N.W.2d 683 (Iowa Ct. App. 1990).
— Iowa Code § 598.21(4) — 37 cases
In Re the Marriage of Hoak, 364 N.W.2d 185 (Iowa 1985).
Markey v. Carney, 705 N.W.2d 13 (Iowa 2005).
In Re the Marriage of McKenzie, 709 N.W.2d 528 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). 1 The Code also contained an additional ground for modification of child support.”
State Ex Rel. Reaves v. Kappmeyer, 514 N.W.2d 101 (Iowa 1994).
In Re Marriage of Byall, 353 N.W.2d 103 (Iowa Ct. App. 1984).
— Iowa Code § 598.21(4)(a) — 13 cases
Markey v. Carney, 705 N.W.2d 13 (Iowa 2005).
In Re the Marriage of Wagner, 604 N.W.2d 605 (Iowa 2000).
In Re the Marriage of Nelson, 570 N.W.2d 103 (Iowa 1997).
Johnson v. Louis, 654 N.W.2d 886 (Iowa 2002).
In Re the Marriage of Pals, 714 N.W.2d 644 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). To constitute a “substantial change in circumstances,” the changed conditions “ ‘must be material and substantial, not trivial, more or less permanent or continuous, not temporary, and must be such as were not within the knowledge or contemplation…”
— Iowa Code § 598.21(4)(i) — 1 case
In Re the Marriage of Stamp, 300 N.W.2d 275 (Iowa 1980).
— Iowa Code § 598.21(4)(n) — 1 case
In Re the Marriage of McKenzie, 709 N.W.2d 528 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). 1 The Code also contained an additional ground for modification of child support.”
— Iowa Code § 598.21(4)(u) — 1 case
In Re the Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004).
— Iowa Code § 598.21(4A) — 1 case
In Re the Marriage of Roseberry, 603 N.W.2d 606 (Iowa 1999).
— Iowa Code § 598.21(5) — 146 cases
In RE the Marriage of Rachel A. McDermott & Stephen J. McDermott Upon the Petition of Rachel A. McDermott, 827 N.W.2d 671 (Iowa 2013). “Other economic circumstances of each party . . .”
Amended July 31, 2015 In RE the Marriage of Susan Michelle Thatcher & Ronald Dean Thatcher Upon the Petition of Susan Michelle Thatcher, Anna Carson as for the Est. of Susan Michelle Thatcher, 864 N.W.2d 533 (Iowa 2015). “Iowa Code § 598.21 (emphasis added). We conclude the plain language of this provision requires a division of property contemporaneous with the decree of dissolution.”
In Re the Marriage of Gensley, 777 N.W.2d 705 (Iowa Ct. App. 2009).
— Iowa Code § 598.21(5)(A) — 1 case
Petition of Bisenius, 573 N.W.2d 258 (Iowa 1998).
— Iowa Code § 598.21(5)(K) — 1 case
In re the Marriage of Harmelink (Iowa Ct. App. 2025).
— Iowa Code § 598.21(5)(a) — 5 cases
In Re the Marriage of Okland, 699 N.W.2d 260 (Iowa 2005).
In re Marriage of Sulentic (Iowa Ct. App. 2025).
In re the Marriage of Nunez (Iowa Ct. App. 2024).
— Iowa Code § 598.21(5)(b) — 6 cases
In re the Marriage of Bojanski (Iowa Ct. App. 2020).
In re the Marriage of Rockwell (Iowa Ct. App. 2019).
In re the Marriage of Barnhouse (Iowa Ct. App. 2020).
— Iowa Code § 598.21(5)(c) — 3 cases
In re the Marriage of Wilde (Iowa Ct. App. 2021).
In re Marriage of Sulentic (Iowa Ct. App. 2025).
— Iowa Code § 598.21(5)(d) — 3 cases
In re the Marriage of Moore, 702 N.W.2d 517 (Iowa Ct. App. 2005).
In re the Marriage of Grove (Iowa Ct. App. 2025).
— Iowa Code § 598.21(5)(e) — 2 cases
In re the Marriage of Johannes (Iowa Ct. App. 2023).
— Iowa Code § 598.21(5)(f) — 2 cases
— Iowa Code § 598.21(5)(g) — 2 cases
In re the Marriage of Shan & Liu (Iowa Ct. App. 2026).
In re the Marriage of Krug (Iowa Ct. App. 2020).
— Iowa Code § 598.21(5)(h) — 2 cases
In re the Marriage of Humphrey (Iowa Ct. App. 2026).
— Iowa Code § 598.21(5)(i) — 3 cases
— Iowa Code § 598.21(5)(j) — 3 cases
In RE the Marriage of Rachel A. McDermott & Stephen J. McDermott Upon the Petition of Rachel A. McDermott, 827 N.W.2d 671 (Iowa 2013). “Other economic circumstances of each party . . .”
In re the Marriage of George (Iowa Ct. App. 2022).
— Iowa Code § 598.21(5)(k) — 5 cases
In re the Marriage of Hansen (Iowa Ct. App. 2018).
In re Marriage of Oyadare (Iowa Ct. App. 2025).
In re the Marriage of Harmelink (Iowa Ct. App. 2025).
In re the Marriage of Wagner (Iowa Ct. App. 2026).
In re the Marriage of Cherny, 919 N.W.2d 766 (Iowa Ct. App. 2018).
— Iowa Code § 598.21(5)(m) — 6 cases
Amended July 31, 2015 In RE the Marriage of Susan Michelle Thatcher & Ronald Dean Thatcher Upon the Petition of Susan Michelle Thatcher, Anna Carson as for the Est. of Susan Michelle Thatcher, 864 N.W.2d 533 (Iowa 2015). “Iowa Code § 598.21 (emphasis added). We conclude the plain language of this provision requires a division of property contemporaneous with the decree of dissolution.”
In re the Marriage of Hansen (Iowa Ct. App. 2018).
In re Marriage of Oyadare (Iowa Ct. App. 2025).
In re Marriage of Sulentic (Iowa Ct. App. 2025).
In re the Marriage of Cherny, 919 N.W.2d 766 (Iowa Ct. App. 2018).
— Iowa Code § 598.21(5A) — 24 cases
In Re the Marriage of Rosenfeld, 668 N.W.2d 840 (Iowa 2003). “” Iowa Code § 598.21 (5A). The court shall determine “the reasonable costs for only necessary postsecondary education expenses.”
In Re the Marriage of Pals, 714 N.W.2d 644 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). To constitute a “substantial change in circumstances,” the changed conditions “ ‘must be material and substantial, not trivial, more or less permanent or continuous, not temporary, and must be such as were not within the knowledge or contemplation…”
In Re the Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006). “(citing Iowa Code § 598.21 (1) (2003)). Importantly, “the property included in the divisible estate includes not only property acquired during the marriage by one or both of the parties, but property owned prior to the marriage by a party.”
In Re Marriage of Kupferschmidt, 705 N.W.2d 327 (Iowa Ct. App. 2005).
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
— Iowa Code § 598.21(5A)(1) — 1 case
In Re the Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004).
— Iowa Code § 598.21(5A)(3) — 1 case
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
— Iowa Code § 598.21(5A)(a) — 5 cases
In Re the Marriage of Neff, 675 N.W.2d 573 (Iowa 2004).
In Re the Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004).
In Re the Marriage of Vannausdle, 668 N.W.2d 885 (Iowa 2003).
In Re the Marriage of Dolter, 644 N.W.2d 370 (Iowa Ct. App. 2002).
— Iowa Code § 598.21(5A)(a)(1) — 1 case
— Iowa Code § 598.21(5A)(a)(2) — 4 cases
In Re the Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006). “(citing Iowa Code § 598.21 (1) (2003)). Importantly, “the property included in the divisible estate includes not only property acquired during the marriage by one or both of the parties, but property owned prior to the marriage by a party.”
In Re Marriage of Kupferschmidt, 705 N.W.2d 327 (Iowa Ct. App. 2005).
In Re the Marriage of Neff, 675 N.W.2d 573 (Iowa 2004).
— Iowa Code § 598.21(5A)(a)(3) — 2 cases
In Re the Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006). “(citing Iowa Code § 598.21 (1) (2003)). Importantly, “the property included in the divisible estate includes not only property acquired during the marriage by one or both of the parties, but property owned prior to the marriage by a party.”
— Iowa Code § 598.21(5A)(a)(l) — 2 cases
In Re the Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006). “(citing Iowa Code § 598.21 (1) (2003)). Importantly, “the property included in the divisible estate includes not only property acquired during the marriage by one or both of the parties, but property owned prior to the marriage by a party.”
In Re the Marriage of Dolter, 644 N.W.2d 370 (Iowa Ct. App. 2002).
— Iowa Code § 598.21(5A)(c) — 1 case
In Re the Marriage of Dolter, 644 N.W.2d 370 (Iowa Ct. App. 2002).
— Iowa Code § 598.21(5A)(d) — 1 case
In re the Marriage of Moore, 702 N.W.2d 517 (Iowa Ct. App. 2005).
— Iowa Code § 598.21(5A)(e) — 7 cases
In Re the Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004).
In Re the Marriage of Pals, 714 N.W.2d 644 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). To constitute a “substantial change in circumstances,” the changed conditions “ ‘must be material and substantial, not trivial, more or less permanent or continuous, not temporary, and must be such as were not within the knowledge or contemplation…”
In Re Marriage of Mullen-Funderburk, 696 N.W.2d 607 (Iowa 2005).
In re the Marriage of Lambertus, 793 N.W.2d 395 (Iowa Ct. App. 2010).
— Iowa Code § 598.21(6) — 36 cases
In Re the Marriage of Weidner, 338 N.W.2d 351 (Iowa 1983).
In Re Jorgensen, 627 N.W.2d 550 (Iowa 2001).
In Re the Marriage of Bolin, 336 N.W.2d 441 (Iowa 1983).
In Re the Marriage of Pals, 714 N.W.2d 644 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). To constitute a “substantial change in circumstances,” the changed conditions “ ‘must be material and substantial, not trivial, more or less permanent or continuous, not temporary, and must be such as were not within the knowledge or contemplation…”
In Re Marriage of Grabill, 414 N.W.2d 852 (Iowa Ct. App. 1987).
— Iowa Code § 598.21(7) — 4 cases
In Re the Marriage of Brown, 776 N.W.2d 644 (Iowa 2009).
In re the Marriage of Rana (Iowa Ct. App. 2021).
— Iowa Code § 598.21(8) — 64 cases
In re the Marriage of Marshall, 394 N.W.2d 392 (Iowa 1986).
In Re the Marriage of Feustel, 467 N.W.2d 261 (Iowa 1991).
In Re the Marriage of Detert, 391 N.W.2d 707 (Iowa Ct. App. 1986).
In Re the Marriage of Gilliam, 525 N.W.2d 436 (Iowa Ct. App. 1994).
In Re the Marriage of Carlson, 338 N.W.2d 136 (Iowa 1983).
— Iowa Code § 598.21(8)(1987) — 1 case
In Re the Marriage of Sjulin, 431 N.W.2d 773 (Iowa 1988).
— Iowa Code § 598.21(8)(Z) — 2 cases
In Re the Marriage of Harvey, 523 N.W.2d 755 (Iowa 1994).
In Re the Marriage of Ober, 538 N.W.2d 310 (Iowa Ct. App. 1995).
— Iowa Code § 598.21(8)(a) — 4 cases
In Re the Marriage of Guyer, 522 N.W.2d 818 (Iowa 1994).
In Re the Marriage of Ales, 592 N.W.2d 698 (Iowa Ct. App. 1999).
In Re the Marriage of Swan, 526 N.W.2d 320 (Iowa 1995).
In Re the Marriage of Staton, 511 N.W.2d 418 (Iowa Ct. App. 1993).
— Iowa Code § 598.21(8)(e) — 1 case
In Re the Marriage of Wessels, 542 N.W.2d 486 (Iowa 1995).
— Iowa Code § 598.21(8)(i) — 1 case
In Re the Marriage of Harvey, 523 N.W.2d 755 (Iowa 1994).
— Iowa Code § 598.21(8)(k) — 3 cases
State Ex Rel. Hunter, by Hastie v. Hunter, 501 N.W.2d 533 (Iowa 1993).
In Re the Marriage of Bethards, 526 N.W.2d 871 (Iowa Ct. App. 1994).
State, Iowa Dep't of Soc. Servs. ex rel. Welter v. Kitner, 512 N.W.2d 309 (Iowa Ct. App. 1993).
— Iowa Code § 598.21(8)(k)(2) — 1 case
State Ex Rel. Baumgartner v. Wilcox, 532 N.W.2d 774 (Iowa 1995).
— Iowa Code § 598.21(8A) — 2 cases
In Re the Marriage of Thielges, 623 N.W.2d 232 (Iowa Ct. App. 2000). “His arguments are based on the decree’s relocation restriction and section 598.21(8A), a provision of the Iowa Code applicable to long-distance relocations.”
In Re the Marriage of Williams, 589 N.W.2d 759 (Iowa Ct. App. 1998).
— Iowa Code § 598.21(9) — 17 cases
In Re the Marriage of Guyer, 522 N.W.2d 818 (Iowa 1994).
In Re the Marriage of McKenzie, 709 N.W.2d 528 (Iowa 2006). “Iowa Code § 598.21 (8) (2003). 1 The Code also contained an additional ground for modification of child support.”
In Re the Marriage of Bolick, 539 N.W.2d 357 (Iowa 1995).
Schuler v. Rodberg, 516 N.W.2d 902 (Iowa 1994).
In Re the Marriage of Axmear, 529 N.W.2d 304 (Iowa Ct. App. 1995).
— Iowa Code § 598.21(A) — 1 case
— Iowa Code § 598.21(A)(1)(b) — 1 case
In re the Marriage of Cherny, 919 N.W.2d 766 (Iowa Ct. App. 2018).
— Iowa Code § 598.21(A)(1)(c) — 1 case
In re the Marriage of Cherny, 919 N.W.2d 766 (Iowa Ct. App. 2018).
— Iowa Code § 598.21(A)(2) — 1 case
In re Marriage of Waller & Kill (Iowa Ct. App. 2025).
— Iowa Code § 598.21(A)(j) — 1 case
— Iowa Code § 598.21(B) — 1 case
In Re the Marriage of Sychra, 552 N.W.2d 907 (Iowa Ct. App. 1996).
— Iowa Code § 598.21(b) — 1 case
— Iowa Code § 598.21(k) — 1 case
In re the Marriage of Cherny, 919 N.W.2d 766 (Iowa Ct. App. 2018).
— Iowa Code § 598.21(l) — 1 case
Nichols v. Nichols, 526 N.W.2d 346 (Iowa Ct. App. 1994).
— Iowa Code § 598.21(l)(a) — 2 cases
In Re the Marriage of Schriner, 695 N.W.2d 493 (Iowa 2005). “2d 205, 207 (Iowa 1987) (citing Iowa Code § 598.21 (1) (1985)). See generally Joseph A.”
In Re the Marriage of Pothast, 539 N.W.2d 199 (Iowa Ct. App. 1995).
— Iowa Code § 598.21(l)(b) — 4 cases
In Re the Marriage of Wendell, 581 N.W.2d 197 (Iowa Ct. App. 1998).
In Re the Marriage of Dean, 642 N.W.2d 321 (Iowa Ct. App. 2002).
In Re the Marriage of Hagerla, 698 N.W.2d 329 (Iowa Ct. App. 2005).
In Re the Marriage of Miller, 452 N.W.2d 622 (Iowa Ct. App. 1989).
— Iowa Code § 598.21(l)(fc) — 1 case
In Re the Marriage of Cooper, 769 N.W.2d 582 (Iowa 2009).
— Iowa Code § 598.21(l)(g) — 3 cases
In Re the Marriage of Lovetinsky, 418 N.W.2d 88 (Iowa Ct. App. 1987).
In Re the Marriage of Woodward, 426 N.W.2d 668 (Iowa Ct. App. 1988).
In Re the Marriage of Ales, 592 N.W.2d 698 (Iowa Ct. App. 1999).
— Iowa Code § 598.21(l)(i) — 2 cases
In Re the Marriage of Rhinehart, 704 N.W.2d 677 (Iowa 2005). “" See Iowa Code § 598.21 (5A)(3) (stating educational expenses not covered by child's expected contribution shall be apportioned by the court to each parent).”
In Re the Marriage of Boyer, 538 N.W.2d 293 (Iowa 1995).
— Iowa Code § 598.21(l)(j) — 3 cases
In Re Marriage of Byall, 353 N.W.2d 103 (Iowa Ct. App. 1984).
In Re the Marriage of Hoak, 364 N.W.2d 185 (Iowa 1985).
In Re the Marriage of Friedman, 466 N.W.2d 689 (Iowa 1991).
— Iowa Code § 598.21(l)(k) — 3 cases
In Re the Marriage of Hansen, 465 N.W.2d 906 (Iowa Ct. App. 1990).
In Re the Marriage of Johnson, 350 N.W.2d 199 (Iowa 1984).
In Re the Marriage of Bries, 499 N.W.2d 319 (Iowa Ct. App. 1993).
— Iowa Code § 598.21(l)(m) — 4 cases
In Re the Marriage of Johnson, 350 N.W.2d 199 (Iowa 1984).
In Re the Marriage of Wendt, 339 N.W.2d 615 (Iowa Ct. App. 1983).
In Re the Marriage of Yates, 365 N.W.2d 49 (Iowa Ct. App. 1985).
Nichols v. Nichols, 526 N.W.2d 346 (Iowa Ct. App. 1994).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.